The real costs of perfect water

By Robert L. Moylan Jr.

Wednesday

Aug 4, 2010 at 12:21 AM

Environmental activists have recently criticized the city for its stand against the EPA over Clean Water Act permits. They scoff at Worcester’s $1.2 billion cost estimate for storm water permit compliance and also object to our planned appeal of the latest EPA permit — that is estimated to cost $200 million to meet nutrient removal requirements at the Upper Blackstone wastewater plant.

These starry-eyed environmental idealists continue to be in denial about the real costs associated with advancing their lofty agenda. They believe that their visions of rivers, streams and lakes restored to pristine conditions that existed before the Pilgrims arrived at Plymouth Rock can come true at minimal cost. They demand unwavering compliance with the strictest of standards while expecting municipalities and districts to employ unproven “green” technologies to meet the latest permit requirements.

For storm water management, the regulatory directive is to meet water quality standards in all waters to which storm water is discharged.

EPA requires this be achieved at all times and conditions, and the leading environmental zealots demand the EPA enforce this provision to the maximum. Storm water managers, on the other hand, recognize that, short of end-of-pipe treatment, it will be impossible to always meet this requirement.

Storm water, after all, is rainfall runoff that travels across streets and parking lots, collecting everything in its path on the way to the nearest body of water. Even with the utmost commitment to sweeping and storm drain cleaning, these are dirty surfaces that will contribute pollutants to runoff.

The $1.2 billion price tag for the Worcester storm water permit was not derived because EPA ordered end-of-pipe treatment, but because they require the city’s storm water to meet water quality standards at all times. Worcester was not alone in its perception of EPA’s expectations. The Conservation Law Foundation (CLF), one of the region’s big players on the environmental advocacy scene, furnished written comments on storm water permits for Worcester and other communities. They made it quite clear that they expect EPA to require that storm water meet water quality standards within the five-year permit term. Communities failing to comply run the risk of substantial monetary fines imposed by EPA and/or lawsuits by organizations such as CLF.

Is Worcester’s hefty $1.2 billion compliance estimate unreasonable and little more than a scare tactic?

If we assume that the end-of-pipe treatment we envision would not be needed, and we just went along with the EPA program, what might that cost? In response to concerns aired by cities and towns about the recent storm water permit for the Charles River and north coastal communities, EPA and their backers estimated compliance costs that relied heavily on the so-called “green” infrastructure, rather than end-of-pipe treatment.

The cost per acre of impervious area ranged from $10,000 to $118,000. Costs in heavily urbanized areas like Worcester would tend to the higher end of this range due to more severe site constraints. EPA has also estimated that Worcester has some 8,785 acres of impervious cover in the form of pavement and rooftops. So, if we apply EPA’s cost estimates to EPA’s impervious cover figure for Worcester, we find the storm water compliance costs could be a paltry $1.04 billion — not too far off from our heavily criticized estimate.

Even if we use a mid-range of $64,000 per impervious acre, the cost for compliance in Worcester would be over $562 million, hardly chump change by anyone’s standards.

Understand that this is a cost that would be paid solely by Worcester’s property owners over the next five years, with little or no financial assistance from the state or federal governments. The pertinent questions that need to be answered are: Do we have a $500 million or $1 billion problem? and Is this where the public’s scarce money ought to be spent?

The situation with the Upper Blackstone wastewater plant discharge permit is similar. The district is spending $180 million to upgrade its plant to meet EPA’s 2001 discharge permit, with Worcester ratepayers contributing 90 percent of that cost. To date, the cost of the upgrades for the typical Worcester ratepayer represents about $165 annually. With the project nearing completion, the effluent quality from the “new” plant is exceptional and will meet the 2001 permit limits.

Nonetheless, in 2008 EPA issued another discharge permit with far more stringent conditions. Achieving this next level of mandated discharge quality will necessitate the construction of costly additional treatment facilities and processes, as the current upgrades cannot assure consistent compliance with the 2008 permit limits. Meeting the 2008 permit will also create a wastewater plant with unsustainable operations that consumes 20 percent more energy, produces 50 percent more sludge and significantly enlarges its carbon footprint while having no meaningful beneficial impact on the river.

On behalf of our ratepayers, fiscal prudence and basic environmental science, we must object to the limits of this new permit.

Worcester wants cleaner lakes, ponds, streams and rivers. But we object to EPA permits based on outdated science, lacking demonstrable, cost effective benefits, and devoid of financial assistance. Dreams of simple, low-cost solutions to meet EPA’s unreasonable unfunded mandates are little more than wishful thinking by those who want the world to be perfect — as long as someone else pays the tab.

Robert L. Moylan Jr. is Commissioner of Public Works and Parks for the city of Worcester.

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